Guidance for the permission activity - B04

The agricultural industry produces packaged grass or green fodder for animal feed, called silage. Silage production on farms commonly uses tyres as weights. This information helps you to understand your responsibilities to reduce the risk of fire from this activity and prevent harm to human health and the environment.

A registration for B04 activity is required to store more than 5m³ of waste tyres at a site at any time for the purpose of use as silage weights.  

Waste tyres used at an activity site in accordance with a registration cannot be used for any other purpose at that site.

You will need a different EPA permission if you use and/or store more than 5m³ of waste tyres (waste code T140) for a use other than producing silage. If you do not wish to obtain the relevant permission, you must remove the tyres that exceed this limit.

You have a responsibility to understand and reduce risks to human health and the environment from your activities.

From the dashboard in the EPA portal click on the Start an application button in the Apply for a permission section.

Follow the guidance for how to apply for a Registration with consideration to the following requirements:

Prescribed permission activity – select activity category B: Primary industry and allied operations and then scheduled activity B04 (Waste tyres – silage production) from the drop-down menus. 

Activity locations – You must specify only one activity location/address per registration application.

Add waste information to activity:

• Only use waste code T140 
• Enter the estimate of the total amount of waste tyres at the activity location (both used in silage production and in storage) in the Amount of waste field and choose the appropriate unit of measure (see EPU values table in Schedule 2 of the EP Regulations if required)
• Enter the estimated maximum amount of silage produced at the activity location in the Amount of silage field and choose the appropriate unit of measure.

Further information about B04 activity and registration

Regulating the storage of waste tyres used for silage production

If you use waste tyres it’s important to store them correctly. If they’re not stored in the right way, it can harm the environment and human health. Waste tyres are hard to extinguish if they catch fire and will release toxic smoke that can cause run off into the environment.

To comply with the environmental protection framework, you need permission (lawful authority) to receive waste tyres. You also need to take reasonable steps to avoid or reduce environmental risks from using and storing these tyres under the general environmental duty (GED).

Registration is a proportionate way to:

• manage these risks
• get the necessary permission  
• comply with the GED.

Apply for B04 registration

You can apply for B04 registration for free on the EPA Portal. The guidance provides a step-by-step guide on how to complete an application. 

Registrations include standard conditions and/or activity-specific conditions. If you hold a registration for using tyres for silage production, you’ll need to meet the outcome-based conditions. This will ensure safe use and storage of tyres, reducing the risk of fire. 

You need to renew your registration every 5 years. 

If at any time, you have more than 5m³ of tyres (about the same capacity of a small sized skip bin) on your site you need to apply for a permission (this means a licence, permit or registration). If you use, or have used, the tyres as silage weights you’ll will need a B04 registration starting from 1 July 2023. If you store between 5m³ and 40 tonnes (or 5,000 EPU) of tyres for any purpose other than silage weights you will need an A09b registration. Storing more than 40 tonnes (or 5,000 EPU) of tyres for any purpose other than silage weights will require an A09a licence. If you store 5m3 or less of waste tyres on your property, you will not need an A09a license, A09b registration, or B04 registration.

A13c registration and tyre usage other than silage production

If you plan to use and store more than 5m³ of waste tyres on your farm for purposes other than silage production, you will need EPA permission. An A13c registration is for small waste and resource recovery operations only. 

If you already hold an A13c registration and no longer need it, you can request its cancellation by sending an email to permissions@epa.vic.gov.au  In your email, make sure to include:

• your permission ID
• permission holder details 
• reason for the request.

Converting 5,000 EPU and 5m³ into number of waste tyres 

To understand the quantity, 5,000 EPU is the same as 5,000 tyres of the size typically used for passenger cars.  Schedule 2 of the Environment Protection (EP) Regulations provides a conversion table for different tyres, both larger or smaller than passenger car-sized ones. The EPUs are used in the EP Regulations to set the threshold for licences for sites storing more than 5,000 EPU or 40 tonnes of waste tyres.

For smaller amounts of waste including waste tyres, the EP Regulations use a volumetric measure. 5m³ is about the same capacity of a small sized skip bin.

Silage-producing farms in different locations 

Each activity site where waste tyres used and stored for silage production needs its own B04 registration. If you want to store waste tyres for silage production at more than one address, you will need separate registrations for each location. For example, if you make silage at one address and then move it to another, you may need a registration for each of those addresses.

It is important to note that the registration requirement applies to individual addresses where the tyres are used and stored for silage production. It does not apply to different locations at the same address. This means that if there are multiple piles of tyres on one property or at one address, you do not need separate registrations for each pile.

Event of a discharge, emission or deposit related to tyres 

When it comes to the B04 activity, the event of a discharge, emission or deposit mentioned in condition REG_G2 refers to any fire incidents that occur on the site involving waste tyres.

Record keeping 

Parts (a) and (b) of condition REG_WM1 apply specifically to waste tyres only. However, part (c) relates to the principle of GED which still applies to other risks of harm to human health and the environment. These risks could include storing and handling farm chemical drums with residues and other wastes generated on site. You must keep and maintain records of these waste materials as part of your overall risk management responsibility under the GED.

You only need to record the locations where you have stockpiled tyres. It is not necessary to record the locations of the tyres being used for silage production.

Storing or accepting wastes other than tyres (condition REG_WM3)

The B04 registration applies to waste tyres (waste code T140) only. If you have questions or need information about storing or accepting other types of waste visit, see Waste duties.

How to manage waste tyres used for silage production to reduce the risk of fire (condition REG_WM5)

To reduce the risk of fire associated with waste tyres used for silage production, it is important to consider various factors such as the amount of waste tyres stored on site and other circumstances specific to your site. For small to medium silage farming activities you can refer to Fire services guideline: Open air storage of new or used tyres. This guideline can help you assess the risks and put practical measures in place to minimise the risk of harm caused by fires related to tyre storage.

For sites with large stockpiles of tyres, extra measures are necessary to minimise risks as much as reasonably practicable. To enhance your knowledge and find more suitable guidance, you can explore other available resources including EPA publication 1667 - Management and storage of combustible recyclable and waste materials – guideline. For more information visit How to store and transport waste tyres and other guidance materials. 

Following your chosen guideline

We expect that you store waste tyres for silage production safely and take the necessary steps to identify environmental risks. It’s important to do everything reasonably practical to remove or minimise risks, especially the risk of fire. The measures outlined or linked to in this guidance can help you in achieving compliance with the General Environmental Duty (GED). The guidance provided for storing and using waste tyres on farms as silage weights is largely based on existing guidance from EPA and the Country Fire Authority (CFA).

We use the information provided in registration applications to guide our planning of compliance activities, including education campaigns and farm inspections. We follow an escalating, risk-based approach to non-compliance outlined in our Compliance and Enforcement Policy. We will work with you to help you understand your obligations and support you to comply.

Contact us

If you have questions about the application for a B04 registration, contact us on 1800 372 842 or email contact@epa.vic.gov.au.